This Privacy and Cookie Policy (the “Policy”) becomes effective on May 1, 2018 for all users. Enhanced data protection rights in this Policy required by the EU General Data Protection Regulation (including, without limitation, the “EEA Resident Rights” described in the “Other Important Privacy Information” section) become effective on May 25, 2018 for all EU-resident users who are natural persons.

We, Concourse Media Ltd., an Ontario corporation with offices at 160 Research Lane, Unit 210, Guelph, Ontario, Canada, N1G 5B2 as the data controller (“Concourse Media,” “we,” or “us”), explain in this Policy how we collect, process and/or use information that we receive via our websites (collectively, the “Platform”) that link to this Policy, as amended from time to time. This Policy describes how Concourse Media collects, processes, uses, shares and secures the personal information you provide. It also describes your choices regarding use and access to your personal information. For purposes of this Policy, personal information shall mean any information relating to an identified or identifiable natural person.

Specific modifications to the default behaviour of Concourse Media websites for EU-resident users have been made to comply with the EU General Data Protection Regulation and are outlined in various sections of this policy. EU-resident users can Opt-In to additional functionality by visiting the Cookie Consent Tool for each Concourse Media property.

This Policy applies only to information we collect, process and use through the Platform.

Information We Collect

We collect information about you to provide our services. In order for us to best provide our services to you (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy. This means that the data collection is largely necessary for fulfilling the relationship we have with you, and where that is not the case, we have a legitimate interest in collecting the information described below.

Information We Collect Automatically

When you use the Platform your device is automatically providing information to us so we can respond and customize our response to you. The type of information we collect by automated means generally includes technical information about your computer or mobile device, such as your IP address or other device identifier, the type of device you use, and operating system version. The information we collect also may include usage information and statistics about your interaction with the Platform. That information may include the URLs of our web pages that you visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, location data (if you have enabled access to your location on your mobile device), and other information about how you used the Platform.

Automated means of data collection include the following:

Cookies And Tracking TechnologiesTechnologies such as: cookies, web beacons, locally shared objects (sometimes called “flash cookies”), mobile identifiers and similar technologies (“Cookies”) are used by Concourse Media and our partners (such as advertising, marketing and analytics providers) (“Ad Partners”). These technologies may be used in analyzing trends, administering the Platform, tracking users’ movements around the Platform and to gather demographic information about our user base as a whole. Our Ad Partners may also use such technologies to deliver advertisements to you. You can control the use of Cookies at the individual browser level, but if you choose to disable Cookies, it may limit your use of certain features or functions on our website or service. For more information on Cookies, how we use them, the third parties we work with who use them, and how you can control them, please see the section entitled Cookie Policy and Ad Choices.

Log File InformationLog file information is automatically reported by your browser or mobile application each time you access a website on our Platform. For example, when you access a Concourse Media website, our servers automatically record certain information that your web browser sends when you visit any website. These server logs include information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, and pages viewed.

Device InformationWe collect information about the device you use to access the Platform, including type of device, operating system, settings, and unique device identifiers, and IP address. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using a Mac or a PC, or an iPhone or Android phone. We also use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software records information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

How We Use Information

We use the information we collect to provide our services. In order for us to best provide our services (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy. This is largely necessary for fulfilling the relationship we have with you, and, where that is not the case, we have a legitimate interest in using the information we collect, including personal information, for these purposes:

to customize and improve the features, performance, and support of the site;

to provide relevant advertising, including interest-based advertising from us and third parties, which may mean that we share non-personally identifiable information, such as aggregated website usage information, to third-party advertisers;

for internal operations, including troubleshooting, data analysis, testing, research, and service improvement (this includes use of your IP address and mobile device information to help diagnose problems with our service and to administer the Platform);

to analyze use of the Platform and improve the Platform;

to create aggregate and statistical data that does not identify you individually and that we can commercialize (for example, we use mobile device data and IP addresses to gather demographic information);

When we collect any information that does not identify you as a specific natural person (“Non-Personal Information”), we are permitted to use and disclose this information for any purpose, notwithstanding anything to the contrary in this Policy, except where we are required to do otherwise by applicable law. Examples of Non-Personal Information include: physical location information; demographic information, or any personal information that has been anonymized, aggregated or de-identified. If applicable law requires that we treat certain Non-Personal Information as personal information, we will use and disclose this information as personal information in accordance with this policy.

How We Share Information

We only disclose your personal information to third parties as follows:

We use affiliated and unaffiliated service providers all over the world (including web servers, cloud storage systems, CRM providers, content support teams, marketing partners, advertising partners, and others) to help us deliver our service and run our business subject to strict confidentiality agreements. These companies are authorized to use your personal information only as necessary to provide these services to us;

We will disclose data if we believe in good faith such disclosure is necessary (1) to comply with relevant laws or to respond to subpoenas or warrants or legal process served on us (though we reserve the right to take action on behalf of our users to defend their right to anonymity when we believe there is a legitimate basis to do so, because candid, lawful, anonymous free speech is fundamental to Concourse Media’s mission of workplace transparency); (2) to enforce our Concourse Media Terms of Use and Privacy Policy; (3) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; (4) as we otherwise deem necessary and is permitted by applicable laws to protect and defend the rights or property of us, the users of our services, or third parties; or (5) as permitted under applicable laws to meet national security and similar requirements;

In the case of the reorganization or sale of our company or assets, your data may be transferred, subject to the acquirer and its affiliates accepting the commitments made in this Policy and compliance with applicable law;

Cookie Policy and Ad Choices

Cookies

Cookies are small pieces of data that are stored on your computer, mobile phone, or other device when you first visit a page. We use cookies, web beacons, locally shared objects (sometimes called “flash cookies”), mobile identifiers and similar technologies (“Cookies”) to help us recognize you on the Platform, enhance your user experience, understand usage of the Platform, and show you relevant advertising. Cookies may also be set by other websites or services that run content on the page you’re visiting.

Cookies used on the Concourse Media websites have been categorized into a number of separate classifications and can be managed separately through our Cookie Consent Tool. Default cookie settings have been set to respect the various regulatory guidelines depending on your country of origin.

Strictly Necessary CookiesThese cookies are necessary for the website to function and cannot be switched off in our systems. You can set your browser to block or alert you about these cookies, but some parts of the site will then not work. These cookies do not store any personally identifiable information.

Performance CookiesThese cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Functional CookiesThese cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly. Functional cookies are disabled by default for users in the EEA but can be enabled through our Cookie Consent Tool.

Targeting & Advertising CookiesThese cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising. Targeting cookies are disabled by default for users in the EEA but can be enabled through our Cookie Consent Tool.

Social Media CookiesThese cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools. Social media cookies are disabled by default for users in the EEA but can be enabled through our Cookie Consent Tool.

What are Cookies used for?

Cookies transmit information about you and your use of the Platform, such as your browser type, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use.

We use Cookies for things like:

SecurityWe use Cookies to enable and support security features, prevent fraud, and protect your data from unauthorized access.

AdvertisingWe use Cookies to deliver, evaluate and improve advertising, for example by using information about you to provide relevant advertising both on and off the Platform. Our Ad Partners may use a cookie to determine whether you’ve already been shown an advert or how it performed, or provide us with information about how you interacted with an ad.

Analytics and PerformanceWe use Cookies to analyze how our visitors use the Platform and to monitor site performance. These Cookies help us to identify and fix errors, understand and improve services, research and test out different features, and monitor how our visitors reach our sites.

Legal ObligationsWe use Cookies, along with your IP address, to determine your country of origin. This collection and processing is required for compliance of our legal obligation under the GDPR to ensure that our website does not collect or process personally identifiable information without consent when accessed from the EEA.

Ad Choices and Managing Cookies

Concourse Media works with several third parties to provide you with personalized, interest-based advertising. We may target ads to you and measure their performance on and off the Platform using:

Cookies (both on and off the Platform) which may include information from the Ad Partners we use to help deliver relevant ads to you.

How We Work with Third-Party Ad Partners

When we work with our Ad Partners to serve you personalized, interest-based advertising, we do not share information with them that they can use to identify you or associate with you as a specific individual unless you have instructed us to do so (such as when you fill out a lead form in an ad, or approve your Profile for display to employers). Similarly, if one of these Ad Partners have information about you saved in one of their own Cookies on your browser, they use that information to help us send you a relevant ad, but they do not share with us information that we can associate with you as an individual. Click here to find out more about how Google uses your information.

We work with third parties, such as Google Analytics, to provide analytics services that use the Cookies set on your device to measure the performance of advertising and track traffic to Concourse Media generally. We have also implemented Google Analytics Demographics and Interest Reporting, which categorizes Cookie information so that we and third-party service providers can better deliver advertisements that are relevant and useful to you on the Platform and various websites across the internet.

Opting Out of Cookies

We use Cookies that are necessary for us to provide the services you use and you cannot opt out of these Cookies on the Platform. You are able to disable placement of some (but not all) Cookies by setting your browser to decline cookies, though this may worsen your user experience. Additionally, you can also control, manage and/or delete cookies via your browser settings. A useful resource for information about deleting and controlling cookies can be found at AboutCookies.org.

Please note: If ads or other features on the Platform are provided by third parties, those parties set and use their own Cookies that are subject to those third parties’ privacy notices and policies. Concourse Media does not have access to, or control over, these Cookies. Also, if you respond to ads posted by third parties or submit information to third parties via the Platform, such third parties receive information about you subject to their privacy policies.

Do Not Track Signals

We do not currently respond to ‘do not track’ signals and similar settings or mechanisms. When you use the Platform, we try to provide a customized experience.

Other Important Privacy Information

EEA Resident Rights

If you are a resident of the European Economic Area, you have the following data protection rights:

If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under “Contact Us“.

In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under “Contact Us“.

Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Notwithstanding the foregoing, we reserve the right to keep any information in our archives that we deem necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

Choices Regarding Your Personal Information

How Long We Keep Your Personal Information

We keep your personal information only so long as we need it to provide the Platform to you and fulfill the purposes described in this Policy. This is also the case for Partners whom we share your personal information with and who carries out services on our behalf. Retention periods can vary significantly based on the type of information and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, resolve disputes and enforce our agreements, we will either remove it from our systems or depersonalize it so that we can’t identify you.

Privacy of Minors

To access or use the Platform you must be 18 or the age of majority in your jurisdiction, or your use of the Platform must be under the supervision of a parent or guardian or other responsible adult. If you become aware that a child has provided us with personal information without parental consent, please contact us here.

Data Controller

The information about you that we collect, process and/or use through the Platform is controlled by Concourse Media Ltd. and the services it provides are hosted and provided outside of the European Economic Area (EEA), including in the United States, for the purposes described in this policy. The privacy protections and the rights of authorities to access your information in these countries may not be the same as in your home country. We take additional measures when information is transferred from the EEA. This includes having standard clauses approved by the European Commission in our contracts with parties that receive information outside the EEA. We also rely on European Commission adequacy decisions about certain countries, as applicable, for data transfers to countries outside the EEA.

Updates to Our Privacy Policy

We may revise this Policy from time to time by posting an updated version on the Platform. This version of the Policy will be effective for you as described at the beginning of the Policy. The revised Policy will be effective immediately. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Platform is subject to the most current effective version of this Policy.

Contact Us

If you have any questions or suggestions regarding this Policy, please contact us here.

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